Challenges and Recommendations for Improved Identification of Low ILUC-Risk Agricultural Biomass

The “low indirect land use change risk” (“low ILUC-risk”) concept was developed to assess whether a given batch of crop-based biofuels competes with other land uses and is likely to stimulate the expansion of agricultural land. At the core of low ILUC-risk is an “additionality principle” that aims to ensure that special policy treatment is only given to biofuel feedstocks that are produced over and above the business-as-usual baseline.

This paper developed as part of the BIKE project tests the European Commission’s methodology for calculating the baseline by applying it to publicly available Eurostat data at national and NUTS2 scales. Statistical and regional variation in yield trends leads to differences in the long-term outcomes of the methodology, which could end up incentivising the diversion of crops into the biofuel sector.

We introduce the terms “tailwind additionality”, “headwind additionality”, and “additionality ratchet” to characterise the phenomena which contribute to this outcome. These form a basis for technical recommendations to improve the methodology and, we hope, enhance both the attractiveness and the robustness of the low ILUC-risk framework.